Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al

Filing 282

Assented to MOTION to Seal SFFA's Letter Motion Regarding Depositions and Custodians by Students for Fair Admissions, Inc..(Caldwell, Benjamin)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
STUDENTS FOR FAIR ADMISSIONS, INC.,
Plaintiff,
v.

Civil Action No. 1:14-cv-14176-ADB

PRESIDENT AND FELLOWS OF HARVARD
COLLEGE (HARVARD CORPORATION),
Defendant.
PLAINTIFF’S ASSENTED-TO MOTION TO FILE UNDER SEAL
PLAINTIFF’S LETTER MOTION REGARDING DEPOSITIONS AND CUSTODIANS
Pursuant to Local Rule 7.2 and this matter’s Stipulated Protective Order (Dkt. No. 55),
Plaintiff, Students for Fair Admissions, Inc. (“SFFA”), hereby brings this assented-to motion
seeking an order to file under seal a letter motion addressing the amount of depositions to be
taken by SFFA going forward in this matter and SFFA’s request for additional custodians based
on recent discovery (the “Letter Motion”).

The Letter Motion will contain substantial

information that has been designated by Defendant as Confidential and/or Highly Confidential –
Attorneys’ Eyes Only pursuant to the Stipulated Protective Order. To comply with Defendant’s
designations, SFFA requests an order that allows the Letter Motion, and all documents in
support, to be filed under seal in its entirety. Pursuant to Local Rule 7.1(a)(2), Defendant was
aware of this motion and assents to it.
WHEREFORE, SFFA respectfully requests that the Court grant this motion and allow the
Letter Motion, along with all accompanying documents in support, to be filed under seal until
further order of the Court and to be viewed only by the Judge, her clerk(s), and Court personnel.

1

Respectfully submitted,
By: /s/ Benjamin C. Caldwell

Paul M. Sanford BBO #566318
Benjamin C. Caldwell BBO #675061
BURNS & LEVINSON LLP
One Citizens Plaza, Suite 1100
Providence, RI 02903
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]

William S. Consovoy
Thomas R. McCarthy
J. Michael Connolly
CONSOVOY MCCARTHY PARK PLLC
3033 Wilson Boulevard, Suite 700
Arlington, Virginia 22201
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Patrick Strawbridge BBO #678274
CONSOVOY MCCARTHY PARK PLLC
Ten Post Office Square
8th Floor South PMB #706
Boston, MA 02109
Tel: [phone]
[e-mail]
Michael H. Park
CONSOVOY MCCARTHY PARK PLLC
2 Columbus Circle, 15th Floor
New York, NY 10024
Tel.: [phone]
[e-mail]

Counsel for Plaintiff SFFA
Dated: April 11, 2017

2

CERTIFICATE OF CONFERENCE
In accordance with Local Rule 7.1(a), I hereby certify that Defendant’s counsel was made
aware of this motion before it was filed and assents to the relief requested therein.

/s/ Benjamin C. Caldwell

CERTIFICATE OF SERVICE
I hereby certify that this document filed through the CM/ECF system will be sent
electronically to all counsel of record via the CM/ECF system.
/s/ Benjamin C. Caldwell

4815-4507-2198.1

3